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Taxpayers will have to think carefully about the jurisdictions they use for their French transactions after the government in Paris published its annual update of countries that it believes do not comply with international standards of exchange of information, adding the British Virgin Islands (BVI), Jersey and Bermuda to the list and removing the Philippines. These changes are retroactive from January 1 this year.

Hutchison Whampoa group companies were battling HM Revenue and Customs (HMRC) in the European Court of Justice (ECJ) yesterday in a case testing whether consortium loss relief may be claimed in the UK by a surrendering company with a non-UK link company and a non-EU parent.

Italy’s financial transaction tax (FTT), implemented in March 2013, has been extended to cover financial derivatives and high frequency trades.

With the rapid development of financial transactions and innovative financial products in China, hybrid investments, which normally have a dual nature of equity and debt investments, have become a popular investment vehicle used by many companies, such as trust companies, in recent years. Examples of such hybrid investments include preferred stocks and convertible bonds from which periodic fixed interests or profits would be derived.

The US Court of Appeals for the Seventh Circuit is the latest appellate court to favour the Internal Revenue Service’s (IRS) broad application of penalties on taxpayers entering into transactions lacking economic substance, after its ruling against Superior Trading.

Type of Deal Value Acquirer Target Adviser to acquirer (tax) Adviser to target (tax) Acquisition $10.4 billion Amgen Onyx Pharmaceuticals Sullivan & Cromwell - Ronald Creamer Goodwin Procter Acquisition $5.2 billion Deutsche Wohnen GSW Immobilien Sullivan & Cromwell Hengeler Mueller Acquisition $3.1 billion Sinopec Group Apache Weil, Gotshal & Manges - Jared Rusman Acquisition $1.9 billion Baidu 91 Wireless Davis Polk & Wardwell Acquisition $1.6 billion Atlas Copco Edwards Group Weil, Gotshal & Manges / Davis Polk & Wardwell Merger $1.6 billion Dole Food David H Murdock Gibson, Dunn & Crutcher / Sullivan & Cromwell - Ronald Creamer, David Passey Paul Hastings Merger $220 million Cullen/Frost Bankers WNB Bancshares Sullivan & Cromwell - Ronald Creamer Haynie Rake Repass & Lowry / Atkins, Hollmann, Jones, Peacock, Lewis & Lyon Acquisition $200 million C.R. Bard Medafor Weil, Gotshal & Manges - Helyn Goldstein Fredrikson & Byron Acquisition $143.9 million Keppel REIT Management 8 Exhibition Street King & Wood Mallesons Acquisition $104.5 million Garda World Security G4S Cash Solutions Stikeman Elliott - John Lorito Acquisition Undisclosed ARM Limited Sensinode Hannes Snellman / Davis Polk & Wardwell Acquisition Undisclosed CPG International Ares Management / Ontario Teachers’ Pension Plan Board Fried, Frank, Harris, Shriver & Jacobson Sullivan & Cromwell - Andrew Mason, David Spitzer Acquisition Undisclosed Facebook Mobile Technologies Fenwick & West - Adam Halpern, Larissa Neumann, Julia Ushakova-Stein Type of Deal Value Issuer/Borrower Lead managers/arrangers Adviser to issuer/borrower (tax) Adviser to lead managers (tax) Senior Notes Offering $500 million Moody's JP Morgan / Merrill Lynch Gibson, Dunn & Crutcher Davis Polk & Wardwell - Michael Mollerus Block Trade $276 million PDC Energy Merrill Lynch Davis Graham & Stubbs Davis Polk & Wardwell - Lucy Farr

Type of Agreement Country Country Date Signed Double Taxation Avoidance Agreement Belarus Sri Lanka August 27 2013 Tax Information Exchange Agreement Isle of Man Switzerland August 28 2013 Tax Information Exchange Agreement Japan Jersey Entered into force August 30 2013

Nélio B Weiss

Donka Pechilkova According to a decision of the Sofia City Court, effectively from June 17 2013, a total of 22 sites for sports betting are forbidden by the State Gambling Committee. The reason is that they do not have the licence required by the Law on Gambling that entered into force last year. Among the online portals are the biggest betting sites in the world. The number of the blocked websites increases every two weeks, due to the new alternative websites that open daily. Officially the amendments, referring to hundreds of millions of leva and are not only connected with betting via the internet, but imposes an unprecedented censorship on the internet, comparable with that of countries like North Korea, China, Iran, Iraq, Syria and others.

Bill Maclagan